Last week the Michigan Occupational Safety and Health Administration (MIOSHA) released its Top 10 citations issued during fiscal year 2025. The list shows hazardous energy control remains a top enforcement focus of the agency.
Part 85 of MIOSHA's General Industry Standards adopts federal OSHA’s Standard on the Control of Hazardous Energy. Like the federal Standard, Part 85 regulates when and how Michigan employers must implement procedures for the lockout/tagout of energy sources during employees' servicing and/or maintenance of machines and equipment. Last year, Part 85's section requiring the implementation of an energy control program ranked among MIOSHA’s most frequently cited items, and Part 85's section on training and communication requirements also appears in the Top 10, signaling sustained focus on documentation and training sufficiency for lockout/tagout programs.
In recent years, Part 85 has become a frequent flyer on MIOSHA's Top 10 citations list. And in the age where artificial intelligence, robotics and other technological advances are reshaping the workforce, Michigan employers might consider reviewing their own energy control practices to ensure their compliance with Part 85. As part of that review, however, employers should be aware of MIOSHA's more limited application of Part 85's exception for minor tool changes and adjustments and other minor servicing activities.
In carrying out the federal Standard, OSHA has allowed employers to rely on control‑circuit systems (e.g., PLC‑based safety functions) as an “alternative measure” for minor servicing when a hazard analysis demonstrates "effective" protection and the system is designed, installed, used and maintained in accordance with good engineering practices. Employers can often achieve this burden through their reliance on applicable manufacturers’ recommendations, prior operating experience and reliability data.
MIOSHA's enforcement of Part 85 is much more rigorous. As MIOSHA's Division Instruction for Part 85 shows, the agency will expect employers to have performed a documented risk assessment supporting any reliance on control-circuit systems for minor servicing activities, prioritizing higher-order controls and layering engineered and administrative measures to achieve effective protection. In practice, MIOSHA will expect the risk assessment to be performed in a manner that is consistent with applicable American National Standards Institute standards.
